Eurostat’s analysis published on March 26, 2025 shows the EU aluminium import market presents a challenge for assessing trade effects under the Carbon Border Adjustment Mechanism (CBAM). Some major trading partners benefit from origin-based exemptions, while others supply a range of products where customs values alone provide limited insight into embedded emissions. The assessment therefore depends on how origin and product coverage are determined for each transaction.
In 2024, EU imports of aluminium and articles thereof under HS Chapter 76 reached €29.5 billion, while exports totaled €18.4 billion. This resulted in a trade deficit of €11.1 billion. The figures cover a broad set of aluminium products rather than only goods classified under CBAM’s specific product codes, but they indicate the EU’s reliance on imported metal and fabricated items.
On an import-value basis for 2024, Norway was the largest supplier at €4.4 billion, or 15.0% of the total. China accounted for €3.9 billion (13.1%), Türkiye for €2.8 billion (9.4%), Iceland for €2.1 billion (7.3%), and Switzerland for €1.7 billion (5.8%). Together, these five countries represented approximately 50.6% of the import value recorded under Chapter 76.
These shares are based on trade value rather than physical volumes and do not directly measure the market’s actual CBAM exposure in 2026. Eurostat’s partner structure also illustrates how origin rules can affect whether imports translate into potential certificate liabilities.
Origin-based exemptions and their effect on CBAM exposure
Goods originating in Norway, Iceland, Liechtenstein and Switzerland are exempt from CBAM under applicable EU rules. The exemption is linked to the relevant emissions-trading arrangements associated with those origins. As a result, import shares for Norway, Iceland and Switzerland carry different implications for certificate liabilities than shares for China or Türkiye.
The exemption depends on legally established non-preferential origin rather than logistics alone. Simply routing goods through an exempt territory does not automatically confer exempt status.
Liechtenstein is included among origins listed as exempt, alongside Norway, Iceland and Switzerland. This distinction affects how trading partner shares should be interpreted when estimating potential CBAM-related costs tied to imports.
CN classification determines whether imports align with CBAM product scope
Product classification is described as another key factor for trade analysis beyond aggregate HS Chapter 76 statistics. CN 76011010 covers slabs of unwrought non-alloy aluminium, CN 76011090 covers other unwrought non-alloy aluminium, and CN 76012080 covers certain unwrought aluminium alloys.
The analysis also requires separate treatment for downstream products such as sheet, foil, extrusions and other fabricated articles. These categories require distinct classification and production-route assessments because they may not correspond to the same product coverage assumptions used for unwrought inputs.
Certain scrap categories are excluded or treated differently, particularly under proposed reforms mentioned in the analysis. This adds further complexity when comparing trade patterns to future compliance obligations.
Import values can change without corresponding changes in tonnage
Eurostat compared 2019 and 2024 and found that the value of EU aluminium imports increased by 29.9%. Over the same period, physical weight declined by 6.2%. The divergence indicates that higher customs values cannot be treated as automatic evidence of increased imported tonnage.
Factors such as global aluminium prices, product composition, exchange rates and trading conditions can raise aggregate import values without increasing physical volumes. Customs unit values expressed in euros per tonne are therefore meaningful only when calculated for sufficiently comparable product categories.
This approach is relevant for CBAM-related assessments because embedded emissions depend on production characteristics rather than customs value alone. Without comparable product groupings, changes in value may reflect shifts in grade or mix rather than quantity.
Matched CN8 data are needed to track monthly partner shifts
Eurostat’s general merchandise-trade release dated October 16, 2026 covered August extra-EU imports but did not include the detailed aluminium country-share matrix needed to establish the sector’s latest monthly movements. A robust comparison would evaluate August 2026 against both July 2026 and August 2025 using the same CN8 product selection across periods.
The analysis would require country-level shares calculated separately by physical weight and customs value. Implied customs unit prices would also need examination for differences in grade and product composition between periods.
Without matched CN8 data, monthly changes in aluminium import shares cannot be established reliably from aggregate trade figures alone. This limits how quickly market-share shifts can be linked to CBAM-relevant coverage assumptions.
CBAM certificate pricing versus supplier cost positions
For imports from covered origins, the published CBAM certificate price for the third quarter of 2026 was €82.32 per tonne of CO₂ equivalent. The analysis notes that a supplier’s overall cost position depends on more than this published price.
Supplier costs also depend on embedded emissions in the goods, the applicable free-allocation adjustment and any qualifying carbon price paid in the country of origin. A supplier with lower verified emissions may offer a more competitive overall position even if charging a higher invoice price.
The comparison is conditional on equivalent goods and comparable production conditions being assessed across suppliers from covered origins.
Downstream expansion could broaden future compliance obligations
The EU’s proposed expansion of CBAM to additional downstream products in 2028 remains subject to negotiations. The European Parliament supported lowering the aluminium threshold from 50 tonnes to five tonnes while widening coverage scope, while other institutions advanced their own positions.
The final provisions will determine which fabricated aluminium products become subject to additional compliance obligations. Assessments must therefore examine relevant CN classifications against both the existing framework and proposed amendments before estimating what portion of the market could become newly exposed.
Eurostat’s partner structure shows why this distinction matters: Norway, Iceland and Switzerland together represented 28.1% of HS Chapter 76 import value in 2024. The figure does not establish that 28.1% of CBAM-covered aluminium imports are exempt because Chapter 76 includes products outside precise CBAM scope and legally determined origin may differ between transactions.
Separating product groups is required to assess market-share shifts
The comparison between 2019 and 2024 reinforces the need to separate product groups when interpreting import trends for CBAM relevance. Higher customs values alongside lower physical weight indicate changes in prices, product mix or both, but aggregate figures cannot distinguish between global aluminium price movements and shifts toward higher-value fabricated products.
A more useful analysis would examine unwrought aluminium grades separately from sheet, extrusions and structures across equivalent periods and partner-country profiles. This approach aligns with how different product categories require different classification assumptions under CBAM coverage considerations.
This creates a more differentiated supplier landscape for buyers in Germany, Italy and Austria as well as exporters in Serbia and the wider Western Balkans mentioned in the analysis context. Relevant distinctions include exempt origin status, verified low-carbon production versus higher-emission covered production, and downstream products whose future CBAM status remains uncertain.
The available broad-market statistics establish dependence on imported aluminium products but do not show that CBAM has already redistributed aluminium market shares across partners or product categories. Establishing such an effect requires product-level trade data alongside verified emissions information and a clear distinction between existing obligations and proposed future coverage.